REILLY TAR & CHEMICAL CORPORATION SITE
ST. LOUIS PARK, HENNEPIN COUNTY, MINNESOTA
Table A. Soil Ingestion EMEGs and CREGs (mg/kg; ppm) used for Selecting Reilly Tar & Chemical Corporation Site Contaminants for Further Evaluation
| Chemical | Pica Child1 EMEG | Child EMEG | Adult EMEG | Adult CREG |
| Acenaphthene* | 120 | 3000 | 42000 | NE1 |
| Anthracene* | 600 | 15000 | 210000 | NE |
| Benzene | NE | NE | NE | 24 |
| B[a]A2 | NE | NE | NE | NE |
| B[b]F | NE | NE | NE | NE |
| B[k]F | NE | NE | NE | NE |
| B[a]P | NE | NE | NE | NE |
| B[g,h,i]P | NE | NE | NE | NE |
| 1,1-Biphenyl* | 100 | 2500 | 35000 | NE |
| Chrysene | NE | NE | NE | NE |
| Cresols (o,m,p) | NE | NE | NE | NE |
| D[a,h]A | NE | NE | NE | NE |
| Ethylbenzene* | 200 | 5000 | 70000 | NE |
| Fluoranthene* | 80 | 2000 | 28000 | NE |
| Fluorene* | 80 | 2000 | 28000 | NE |
| I[1,2,3-c,d]P | NE | NE | NE | NE |
| 2-Methylnaphthalene | NE | NE | NE | NE |
| Naphthalene | NE | NE | NE | NE |
| Phenol* | 1200 | 30000 | 420000 | NE |
| Pyrene* | 60 | 1500 | 21000 | NE |
| Toluene* | 400 | 10000 | 140000 | NE |
| Xylenes* | 4000 | 100000 | 1400000 | NE |
Table B. Drinking Water EMEGs and CREGs (ug/L; ppb) used for Selecting Reilly Tar & Chemical Corporation Site Contaminants for Further Evaluation
| Chemical | Child EMEG | Adult EMEG | Adult CREG |
| Acenaphthene* | 600 | 1200 | NE1 |
| Acenaphthylene | NE | NE | NE |
| Anthracene* | 3000 | 11000 | NE |
| B[a]A2 | NE | NE | NE |
| B[b]F | NE | NE | NE |
| B[k]F | NE | NE | NE |
| B[a]P | NE | NE | NE |
| B[g,h,i]P | NE | NE | NE |
| Chrysene | NE | NE | NE |
| Cresols (o,m,p) | NE | NE | NE |
| D[a,h]A | NE | NE | NE |
| Fluoranthene* | 400 | 1400 | NE |
| Fluorene* | 400 | 1400 | NE |
| I[1,2,3-c,d]P | NE | NE | NE |
| 2-Methylnaphthalene | NE | NE | NE |
| Naphthalene | NE | NE | NE |
| Phenanthrene | NE | NE | NE |
| Phenol* | 6000 | 21000 | NE |
| Pyrene* | 300 | 1100 | NE |
Minnesota Recommended Allowable Limits (RALs) for Reilly Tar & Chemical Corporation Site Contaminants in Groundwater
| Chemical | RAL (ug/L) | Basis for RAL1 | |
| 1. | PAHs | ||
| Acenaphthene | 4000.0 | NC | |
| Anthracene | 2000.0 | NC | |
| Fluoranthene | 300 | NC | |
| Fluorene | 300 | NC | |
| Naphthalene | 30 | NC | |
| Total other noncarcinogenic2 | 0.3 | NC | |
| Total carcinogenic2 | 0.03 | C | |
| 2. | Other Chemicals | ||
| Cresols (o,m,p) | 30 | S | |
| Phenol | 4000 | S | |
2 For the other noncarcinogenic PAHs, RALs are set to be protective against unknown health effects (there is little of no toxicological data on them). For the noncarcinogenic PAHs other than the five listed above, the RAL is 0.3 ug/L. This RAL is compared to their total concentration in the drinking water sample. For all carcinogenic PAHs (see the table in the Toxicological Evaluation subsection), the RAL is 0.03 ug/L. Again, this RAL is compared to the total concentration of carcinogenic PAHs in the drinking water sample. For example, if each of the fifteen carcinogenic PAHs were found in a private drinking water well at 1.0 ug/L, the RAL would be exceeded (15 ug/L vs. the RAL of 0.3 ug/L) and appropriate actions would be taken by MDH.
Carcinogenic and Other PAHs As Defined In the 1986 CD-RAP
| 1. | Carcinogenic PAH: | |
| Benz[a]anthracene | Benzo[b]fluoranthene | |
| Benzo[j]fluoranthene | Benzo[ghi]perylene | |
| Benzo[a]pyrene | Chrysene | |
| Dibenz[ah]anthracene | Indeno[1,2,3-cd]pyrene | |
| Quinoline | ||
| 2. | Other PAH: | |
| Acenaphthene | Acenaphthylene | |
| Acridine | Anthracene | |
| Benzo[k]fluoranthene | 2,3-Benzofuran | |
| Benzo[e]pyrene | Benzo[b]thiophene | |
| Biphenyl | Carbazole | |
| Dibenzofuran | Dibenzothiophene | |
| 2,3-Dihydroindene | Fluoranthene | |
| Fluorene | Indene | |
| Indole | 1-Methylnaphthalene | |
| 2-Methylnaphthalene | Naphthalene | |
| Perylene | Phenanthrene | |
| Pyrene | ||
This appendix was not available in electronic format for conversion to HTML at the time of preparation of this document. For a hard copy, please contact:
Summary of the Public Comments Received by the Minnesota Department of Health Regarding the Reilly Tar & Chemical Corporation Site
The Minnesota Department of Health (MDH) obtained mailing lists of concerned citizens and state and local government officials from the Minnesota Pollution Control Agency Office of Public Information and the city of St. Louis Park. A copy of the draft Public Health Assessment for the Reilly Tar & Chemical Corporation site was mailed to each of these interested parties along with a request for written comments on any aspect of the document. The MDH also issued a press release to local newspapers that summarized the major findings of the draft assessment and gave information on how to obtain a copy of the draft assessment from MDH.
Written comments on the draft Public Health Assessment were received from two parties during the 30-day public comment period. MDH appreciates their time and efforts in making these comments.
One letter with five comments came from the City of St. Louis Park. Two comments suggested changes in grammar; the other three (with MDH responses) are summarized below:
| 1. | Comment - Change: "Reilly completed a Remedial Investigation (RI) for the area directly
east of the Site (referred to as the Northern Area)...." to: "The City of St. Louis Park completed a
final Remedial Investigation [for the Northern Area] on Reilly's behalf."
MDH Response - The change was made in the draft Public Health Assessment |
| 2. | Comment - Change: "Reilly submitted a final RI report for the St. Peter aquifer...." to: "The
City of St. Louis Park submitted a final RI report [for the St. Peter aquifer] on Reilly's behalf."
MDH Response - The change was made in the draft Public Health Assessment |
| 3. | Comment - Change the following sentence: "The groundwater discharge from W23 is routed
to the GAC treatment facility prior to discharge." to read: "The groundwater discharge from
W23 is routed to the GAC treatment facility currently treating the discharge from Drift-Platteville source control wells W420 and W421. The treated water is discharged to Minnehaha
Creek."
MDH Response - The change was made in the draft Public Health Assessment |
The other letter with written comments came from a citizen of St. Louis Park. The comments (or a concise version) and MDH responses are as follows:
1. Comment - The Summary subsection of the draft Public Health Assessment "should include a statement that indicates that although due warnings [regarding contamination] were provided by residents, no action was taken by local government for forty years".
MDH Response - The Summary subsection of the Public Health Assessment is intended only to provide the reader with a very brief overview of the document. An expanded history of the contamination at and around the Reilly Tar & Chemical Corporation site, and response actions by local and state government are given in the Background subsection of the Public Health Assessment. MDH feels that this discussion gives citizens sufficient background to understand the contamination problems at the Site. However, for a more detailed account of these issues, interested readers are referred to the documents listed in last two paragraphs of the Background subsection of the Public Health Assessment.
2. Comment - With respect to the MDH's conclusion in the Summary that "the Reilly Tar & Chemical Corporation site does not pose an apparent public health hazard", five facts that do not "bear out such a foregone and (unintentional) politically expedient conclusion" were made: Fact 1. There is a tremendous quantity of hazardous materials remaining on site; Fact 2. Public funds will be necessary for many years to maintain the status quo (for example, carbon filtration); Fact 3. It is unclear how highway construction in the vicinity of the site will affect soil stability and contaminant migration; Fact 4. Multi-aquifer wells may have an adverse impact upon future water quality; Fact 5. Statistically significant increases in breast cancer may not yet be attributable to the contamination, but neither are they unattributable.
MDH Response - Fact 1: Estimates of the volume of contaminated soil materials range as high as one million cubic yards, both on- and off-Site. The MDH has recommended that on-Site surface and subsurface soils be sampled for the presence and amount of contamination (see Recommendation subsection).
Fact 2: The City of St. Louis Park realized/realizes that under the provisions of the CD-RAP it would incur some long-term expenses. These planned expenses were incorporated, and will be incorporated into the City's future budgets (personal communication with the City of St. Louis Park). Fact 3: The excavated soils from this construction are currently kept in the area of the interchange construction; however, they were placed on a liner, covered, and a fence put around them to minimize contact with them. Fact 4: In 1978-1979, the MDH contracted for the closure of 29 multi-aquifer wells. The RAP contains provisions for investigating abandoning leaking multi-aquifer wells open to the Mt. Simon-Hinckley, Ironton-Galesville, and Prairie du Chien aquifers. Fact 5: The issue of an increase the breast cancer rate in St. Louis Park is discussed in Community Health Concerns Evaluation subsection of the Public Health Implications section of the document.
The Public Health Assessment for the Reilly Tar & Chemical Corporation site gathered information about hazardous substances known to be present at the site and evaluated whether exposure to these substances might cause any harm to people. MDH made the conclusion that "the Reilly Tar & Chemical Corporation site does not pose an apparent public health hazard" based on the review of available environmental sampling data, local health data, and community concerns about the Reilly site. While MDH obtained this information from a number of sources including the Minnesota Pollution Control Agency, the City of St. Louis Park, the Minnesota Department of Health, and the U.S. Environmental Protection Agency, this conclusion was based only on MDH's review and interpretation of this information.
3. Comment - [As stated in the Background subsection of the document] What public health or other action was taken as a result of well contamination documented during the 1930's through 1950's.
MDH Response - The Background section of the document is intended to give readers a general introduction to the Site's history and thus, gives only a very brief description of these issues. More detailed information on actions taken during those years can be found in references cited at the end of the Background section.
4. Comment - [With regard to contamination detected at the Site during the 1930' through the 1950's] Why is leaving the contamination in the soil acceptable, when it is highly likely that your successor(s) will not feel that this was an acceptable decision?
MDH Response - Speculation on decisions to be made by MDH at any time in the future is not possible. The MDH will make their decisions regarding public health issues based on many considerations including the facts of the particular situation, consultations with other state and/or local governmental agencies and professional judgment.
5. Comment - Site visits by MDH and MPCA staff were made during the months of March and April. At those times they may not have been aware of the all the activities that the park is used for nor see the migratory waterfowl that gather at the park.
MDH Response - Based on this comment, MDH staff made an additional visit to the Site in early May, 1992. Observations made at this time are now noted in the Site Visit subsection. MDH noted the presence of geese in the on-Site pond in the draft document.
6. Comment - Residents of the on-Site rental units have not been made aware of the potential dangers of growing food items or handling soil in their yards.
MDH Response - Although there is very little data on actual levels of contamination in the on-Site soils, MDH has assumed that subsurface soils in areas of the Site are contaminated (see discussion of the OPERABLE UNIT: NEAR-SURFACE CONTAMINATION). MDH has added the recommendation for a thorough investigation of all on-Site soils. The City of St. Louis Park has stated that property managers responsible for the housing units on the Site are aware of subsurface contamination and that they are to notify residents. For example, excavation, even for installing posts, can't be undertaken without the knowledge of the city. Even though these controls are in place, MDH has included contact with contaminated soils as a potential route of human exposure to Site-related contaminants because of the present uncertainty as to the actual levels of soil contamination (see Potential Exposure Pathways subsection of the Pathways Analyses section). This information would also be invaluable for proceeding with in-place soil remediation (see Comment 15, below).
7. Comment - Why was nothing done at the time [regarding the complaints about odors and the presence of contaminants in private wells, soil, and surface water prior to the 1970's], when action might have ameliorated or eliminated the present problem?
MDH Comment - During that period, the MDH was not adequately staffed (or funded) to investigate the potential impact that exposure to contaminants from dumps/waste sites would have on human health. However, in 1987, the MDH began to receive funding from the federal Agency for Toxic Substances and Disease Registry (ATSDR) to assess any current or future impact on the public's health posed by the release of hazardous substances into the environment from Superfund sites. This assessment is carried-out after MDH evaluates all of the available environmental data, health data, and community health concerns for the site. The conclusions of this assessment are released to all interested parties in the form of the Public Health Assessment document. Again, more detailed information on actions taken during those times can be found in references cited at the end of the Background section.
8. Comment - Toxic Chemical Release Inventory (TRI) data from 1989 and 1990 is available and should be included in the document.
MDH Response - TRI data for 1989 and 1990 has been added to the document.
9. Comment - Microbiological degradative processes [in soil] aren't going to do much good for regions of high contamination saturation.
MDH Response - The MDH agrees that very high contaminant levels in soils may be inhibitory to microbial degradation. The document has been amended to reflect this view.
10. Comment - What about migratory waterfowl accumulating site-related chemicals in their bodies from surface water and sediment of the on-site pond?
MDH Response - MDH agrees that migratory waterfowl may be exposed to site-related chemicals such as PAHs during ingestion of sediment and water from the pond. However, the following three points should be considered in relation to this comment: 1) PAHs are susceptible to numerous degradative processes in both surface waters and sediment, 2) metabolism of PAHs in tissues of humans and animals renders them more water-soluble and thus more excretable, 3) the on-site surface water/sediment are only accessible to waterfowl during certain parts of the year, thus limiting potential exposure and 4) while waterfowl are not humans, PAHs have not been detected in surveys of human fat tissue and other biological media presumably because these chemicals are fairly rapidly metabolized [and subsequently excreted]. Thus, while limited exposure to PAHs may occur, their long-term accumulation in the tissues of waterfowl and other animals is considered to be minimal.
11. Comment - No ambient air data have been collected on or near the site, even though the air is an obvious transmission medium during construction of the highway project which lies on and abuts the site.
MDH Response - Conversations with the City of St. Louis Park regarding this comment revealed that the City carried out an air monitoring program during phases of the Louisiana Avenue/Highway 7 construction project. Air monitoring for organic vapors (using an HNu meter) took place from June through October, 1991 at the perimeter of the construction zone. There were no reported organic vapor measurements above background at any sampling point during that sampling period. On July 2, 1991, one upwind and two downwind 10-hour air samples were collected using personal air samplers during construction activities in an area south of Walker St. and north of Highway 7. The samples were analyzed for semivolatile organic compounds listed on the U.S. EPA Target Compound List; chemicals on this list include phenolics, carcinogenic PAHs, and noncarcinogenic PAHs. None of these chemicals was found above the reportable detection limit.
This information has been added to the Environmental Contamination and Other Hazards subsection.
12. Comment - Restricting access to certain portions of the park is a temporary fix, not a long-term viable solution.
MDH Response - MDH completely agrees. The Recommendations subsection of the document has been changed to reflect this position.
13. Comment - There was an observed excess of breast cancer in St. Louis Park during 1969-1971. MDH should initiate a follow-up epidemiological study in the area targeting carcinogenic and teratogenic phenomena relating to the PAH substances found there.
MDH Response - An observed excess of breast cancer during that period was noted by MDH. MDH addressed the feasibility of conducting an epidemiological study of the relationship between drinking water and health (breast cancer included) in 1985. Portions of this feasibility study were discussed in the Community Health Concerns Evaluation subsection of the Public Health Assessment. Interested readers can obtain a copy of the complete report from the MDH Section of Chronic Disease Epidemiology.
14. Comment - The sediment of Oak Pond (the on-site pond) should be tested immediately and at annual intervals for suspect substances.
MDH Response - Neither contact with surface water/sediment of Oak Pond nor ingestion of waterfowl that use the pond is considered to be a route of exposure to Site-related contaminants. However, because of the lack of data regarding potential contamination of the pons surface water and sediment, MDH has added a recommendation for the testing both media.
15. Comment - The potential of using various remedial technologies (including new technologies) for soil and groundwater contamination should be investigated.
MDH Response - Testing and/or planning of remedial technologies to clean-up soils is currently
in progress: 1) The University of Minnesota is currently in the first year of a two-year study to
determine the treatability of the contaminated soils, 2) The U.S. EPA SITE (Superfund
Innovative Technologies Evaluation) Program is looking at soil treatability technologies, and 3)
The City of St. Louis Park is beginning to look at technologies for treating the soils excavated
during highway construction.
